Compliance

THE FORTUNE SOCIETY, INC.

CORPORATE COMPLIANCE PROGRAM

SUMMARY

Effective as of January 9, 2017

Introduction: To underscore The Fortune Society, Inc.’s (“Fortune”) commitment to a strong and ethical corporate culture and to assure continued compliance with Federal and State laws, the Fortune Corporate Compliance Plan encompasses eight (8) key elements that have been identified as requirements by the New York State Office of the Medicaid Inspector General (“OMIG”) and the Department of Health (“DOH”).

Key Elements of Fortune’s Corporate Compliance Program:

Written Policies and Procedures, Code of Conduct, and Corporate Compliance Plan. Fortune is required to develop written policies and procedures which establish its standards and code of conduct. On an annual basis or more frequently if necessary, these policies are developed, reviewed, and revised as necessary and are provided to all new hires at orientation and to all existing employees, executives, board members and other individuals associated with Fortune. A full copy of Fortune’s Corporate Compliance Plan is available upon request.

Fortune is committed to maintaining high quality care and services as well as integrity in its financial and business operations. Therefore, Fortune will conduct appropriate screening of key providers, employees, independent contractors and health related business vendors to ensure that they have not been sanctioned by a Federal or State law enforcement, regulatory or licensing agency. These exclusion checks shall be done in accordance with the guidance as outlined in the Office of the Inspector General, Department of Health and Human Services (“OIG”) 2013 guidelines.

Adherence to the Corporate Compliance Program is a condition of employment and businesses’ affiliation with Fortune.

Designation of Chief Compliance Officer. The Chief Compliance Officer reports to the President/CEO of Fortune and has full access to the Board of Directors for the purposes of advising and making recommendations about compliance procedures and issues. The Chief Compliance Officer oversees the Corporate Compliance Plan, supervises training and educational programs in connection with its implementation, oversees the policies and procedures related to compliance efforts and audits programs for compliance. In addition, the Chief Compliance Officer is responsible for the handling of all complaints or allegations of fraud, waste or abuse (whistleblowing) made under the Corporate Compliance Program.

The Chief Compliance Officer for Fortune is Leonard Chavis – his contact information is: lchavis@fortunesociety.org; his landline telephone number at Fortune is (718) 517-7948. In the Chief Compliance Officer’s absence, the following individual has been designated as the alternate contact: Benjamin Metsch – Director of Contract Review and Compliance – his contact information is: bmetsch@fortunesociety.org and his phone number is (347) 510-3659.

Education and Training. New hires will receive training related to Fortune’s overall Corporate Compliance Program during orientation. All existing employees, executives, board members and other individuals associated with Fortune will receive compliance training on an annual basis either in person or through the use of a self-study packet.

Open Lines of Communication. All employees, executives, board members and other individuals associated with Fortune have an affirmative duty and responsibility to report any known or suspected misconduct. Fortune maintains an “open door” policy to encourage the reporting of any problems or concerns. Fortune also maintains a Compliance Hotline where any employee, executive, board member or other individual associated with Fortune can report their compliance concerns to the Chief Compliance Officer via voicemail. The telephone number for the compliance hotline is (347) 510-3450. Information may be offered anonymously over the hotline.

Enforcement and Disciplinary Policies. Fortune applies progressive discipline that is consistent with the severity of the violation of the Corporate Compliance Program. Such discipline can include either suspension or termination.

Monitoring and Auditing Systems. The Chief Compliance Officer routinely conducts corporate compliance audits across all of Fortune’s systems. The Medicaid programs are subject to special scrutiny to identify areas of risk. Findings from such audits will be reported to the President/CEO and the Board of Directors.

Response and Prevention Systems. Through reporting and audit findings and after a comprehensive investigation there is determined to be a substantiated violation of the Corporate Compliance Plan, Fortune shall (1) initiate immediate corrective action which may include the making of prompt restitution of an overpayment amounts, notifying the appropriate governmental agency and the institution of proper disciplinary action; and (2) implementing systemic changes to prevent a reoccurrence of a similar violation in the future.

Policy of Non-Retaliation for Good Faith Reporting. Whistleblowers are protected. In accordance with Fortune’s policies and procedures, all employees, executives, board members and other individuals associated with Fortune are strictly prohibited from engaging in any act or conduct which results in, or is intended to result it, retaliation or retribution against any individual who reports a possible violation of the Corporate Compliance Plan.

This summary is an adjunct to the full Corporate Compliance Plan. It is expected that all employees, executives, board members and other individuals associated with Fortune will have read the full plan in its entirety.

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